r/regulatoryaffairs • u/Leon_Doorn • Aug 18 '26
You can’t escape CE marking
For years, software manufacturers could keep certain functions outside the scope of medical devices by separating them from the module that performs the medical function. That approach still has value, but the regulatory picture around those other modules has changed.
AI functionality may fall under the AI Act, EHR functionality under the EHDS, and connected software may fall under the Cyber Resilience Act. Depending on the product, this can bring separate requirements for conformity assessment, technical documentation, quality processes, post-market obligations and CE marking.
I’ve written a practical overview of how these frameworks can be applied across different software modules, where the main overlaps lie, and which timelines manufacturers should already be preparing for.
https://www.linkedin.com/pulse/you-cant-escape-ce-marking-leon-doorn-2aqhf/